THOMPSON COBURN TRADE ALERT – EXPORTS
HEADLINE	EU & Canada Retaliation Announcements Against March 12 Section 232 Steel/Aluminum Tariffs
DATE	March 12, 2025
EFFECTIVE DATE	Canada: March 13 2025 at 12:01 am EU: April 1 2025 (Phase 1) and mid-April (Phase 2)
BACKGROUND	President Trump signed Proclamations on February 10 removing country-based and product-based exclusions for steel and aluminum, which went into effect on March 12.   The February 10 Proclamations also placed 25% duties on derivative steel and aluminum articles but notably suspended these until the Secretary of Commerce published that it had systems in place to collect tariffs on derivative articles. The Department of Commerce and U.S. Customs and Border Protection (CBP) announced on March 11 at 4:45 p.m. and 9:05 p.m., respectively, that the agencies now had systems in place and would begin implementing the 25% tariffs on steel and aluminum derivative articles on March 12 at 12:01 a.m., giving importers less than three hours’ notice before collecting these additional duties on these derivative items.
DETAILS	Canada: Canada announced 25% retaliatory tariffs on March 12 in response to the United States’ steel and aluminum tariffs. This 25% applies to C$29.8 billion in product imported from the U.S., effective on March 13, 2025, at 12:01 a.m., and will “remain in place until the U.S. eliminates its tariffs against Canadian steel and aluminum products.” A searchable spreadsheet of both the March 4 and March 13 lists available here. European Union: In response to the aluminum and steel tariffs, the EU announced a two-pronged approach:   – Reimpose the EU’s 2018 and 2020 retaliatory tariffs issued against Trump’s first rounds of steel and aluminum tariffs in his first term, effective April 1, 2025, after being suspended since 2022. These countermeasures target a range of U.S. products that respond to the economic harm done on €8 billion of EU steel and aluminium exports.   – Implement new countermeasures package on U.S. exports following a two-week EU stakeholder consultation. This new package would come into force by mid-April. The legal basis for this act will be the Enforcement Regulation (Regulation (EU) No 654/2014).   The EU announced it will be targeting a mix of industrial and agricultural products with its new measures. – Industrial products include i.e.- steel and aluminum products, textiles, leather goods, home appliances, house tools, plastics, wood products. – Agricultural products include i.e.- poultry, beef, certain seafood, nuts, eggs, dairy, sugar, and vegetables.   The Commission has stated these countermeasures will affect €26 billion of U.S. exports to “match the economic scope of the U.S. tariffs.” The full list of initial proposed target products is located here. Various media reports claim that President Trump plans to respond to the EU counter-tariffs.   United Kingdom: The U.K. did not join the EU in its decision to retaliate immediately but affirmed that it reserves the right to do so if deemed necessary.
HTS/PRODUCTS	Canada: List of products from the United States subject to 25 per cent tariffs effective March 13, 2025 – Canada.ca. Also included in our spreadsheet under Sheet “Canada Tariffs – Mar-13″ EU target list (fully searchable): Spreadsheet EU (proposed only): https://circabc.europa.eu/ui/group/e9d50ad8-e41f-4379-839a-fdfe08f0aa96/library/9f483239-477f-4f14-8e2a-a09e1edb1f3d/details?download=true
CITE	Canada: Canada responds to unjustified U.S. tariffs on Canadian steel and aluminum products – Canada.ca   EU: Commission responds to unjustified US steel and aluminium tariffs with countermeasures – EU 2018 Tariffs: Commission Implementing Regulation (EU) 2018/886  (20 June 2018) – 2018 Annexes: G/L/1237 ; G/SG/N/12/EU/1 – EU 2020 Tariffs: Commission Implementing Regulation (EU) 2020/502 (April 6, 2020)   U.K.: News Article — Bloomberg Government

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